10 replies to this topic

[TimG]

So, I will preface this by saying that nonsense is a matter of opinion. I seen someone earlier say he got a minor NC for one solitary ant found, and it got me wondering, how often do we push back? When do you think it's appropriate to push back?

 

Now to the comedy: 

I had an auditor give me 2 NC's in a recent audit (not GFSI). Their audit has requirements NOT listed on the standard. As in, there is no possible way I would know they were a requirement. I let them know it was not listed on the standard, they upheld. Ok, no biggy. I will pass the audit either way and it's not 'scored' but I'm not just going quietly into the night. The following is word for word my RC description.

 

Root cause analysis, what caused the NC:

This audit checklist requirement not being in the actual XX standard.

Also, disagree with determination that notification of supplier isn't inherently implied in the document when it states there is 'rejection for positive results' on testing. As if the rejected loads would magically disperse into the ether.

 

 

Anyone else had some doozies they can share for giggles?

[Tony-C]

Hi Tim,

 

Auditor sounds like a bit of a muppet, send your response and move on, I'm sure you have got bigger fish to fry. 

 

Allowing things like to this to nark you are a waste of energy.

 

I have have contested NCs in the past but usually major ones, for example I justified not having a metal detector based on existing controls and no metal complaints going back over 5 years.

 

BRC subsequently changed the standard to make metal detection compulsory (unless a more effective control measure was in place).

 

Kind regards,

 

Tony

[GMO]

I would say it's increasing with the level and number of inexperienced auditors.  I don't mean "not trained to audit" but "having barely any food industry experience".  We have a crisis in this in my view due in no small part to auditing CBs paying peanuts and retirement of the old guard.

 

I don't do a lot of auditing now but when I do, any non con is raised at the time and discussed so there is the chance to clarify my misunderstanding and that happens.  Likewise though I'm not a pushover.  

 

It seems as though the non con in your case was semantics.  The older I get the more inclined I am to not fully ignore the procedure but not to get hung up about it.  What happens in practice is more important.  I'm still a stickler but stuff like the above (if I felt it was an issue, which I don't) would be more likely to go on the "I'm not going to record this but think it's a good idea to close this gap" list.  I.e. the list the TM is producing themselves (we all know we do).

 

Have I pushed back?  Yes.  I always do with anything I think is BS but likewise I never push back on something I think is genuine.  I know others will.  If you find a genuine gap, I'm not "producing" evidence to "prove" it's not.  Some sites sadly will.  But I'll fight on something I think is BS.  I have had that twice with AIB and both times got them removed on the audit.  Although I almost always disagree how AIB score, I rarely push back on that unless it's extreme because I normally find it balances out.  E.g. they score what I think is a minor issue as a more significant one but also a more significant as minor as well.  But AIB are funny on scoring anyway.  I often walked away thinking "i'd have guessed at the same number but would have got there a different way."  At that point I shrug and figure it's not worth the battle.

[TimG]

 "We have a crisis in this in my view due in no small part to auditing CBs paying peanuts and retirement of the old guard."

Absolutely. I've had 8 audits over the past year, only 3 of them were from people who've audited before and 2 of them were retiring within the year (last year). 

And to clarify, these things are low on my nark list. I actually enjoy giving them a bit of hell in my responses, but at the end of the day I know we're all just trying to do our jobs. I've only once in my 15 years in food had an auditor I'd consider a true jerk (self important, my way or the highway, etc) and thankfully that was very early in my food safety career so I was only riding second chair on the audit.

[jfrey123]

..I justified not having a metal detector based on existing controls and no metal complaints going back over 5 years.

 

BRC subsequently changed the standard to make metal detection compulsory (unless a more effective control measure was in place).

So you're the guy who ruined it for everybody lol jk.

 

When I was primarily consulting with my partner, it was our job to push back on non-sense.  Mostly we try to address our concerns with their perception before the report gets published, because it's a more drawn out process to appeal the findings later and it can cause a black mark on the auditor's record if too many of their findings are overturned.  We didn't want that for them, but we also wanted the best score for our clients.

 

One SQF auditor was ready to give a client a finding for an exterior door's self-closer being broken.  We had to pull up the code (11.1.5.1) which states "external access personnel doors" shall have a self-closing device.  The door in question was not permitted by the plant to be used for personnel except as an emergency exit and was effectively sealed against pests.  It was shown on the flow maps as non-access, it was marked with signs to prohibit entry/exit, and employee training had them effectively using the designated entrances to this storage area.  The closer looked 'broken' because it had been cannibalized for parts to fix other door closers.  We had told her this during the walkthrough when she saw it, to which she nodded and said okay, but then tried to bring it up back during our closing meeting and we had to argue it again with the code in front of us all.

 

Another one was at my first spice plant.  Small time customer sends an auditor who seemed like a bored old dude, so really no one was taking his visit seriously (not even him, honestly) until we got to the break room.  He informed us that a thermometer in the employee refrigerator along with a checklist for monitoring (every hour I think he claimed) was an SQF requirement.  Told him, 'Nope, that's not in the code anywhere.  Not spelled out in any guidance.'  He told me he thinks I'm wrong but moved on in a way that I thought it was over.  Week later we get the 'report' from our customer and it had this as a finding they demanded a CAPA for.  Wanted to tell them to p-off, but boss made me word it more diplomatically:  "We have reviewed and find ourselves to be in compliance with the SQF standard, as have our three prior SQF auditors, but will make a note to consider this during any future improvements."

 

My boss man has also pushed back on a critical before.  Currently not consulting, we're both working where a company makes fruit and veg trays at various sites.  A new tray at one site had them putting pre-packaged single servings of baby carrots into one of the bins of the tray.  The HACCP states all the fruit and veg goes through a wash cycle for (I think) 30 seconds minimum.  When operations started the new line, we in corp QA told them they needed to wash the little baggies of baby carrots and they did, except they half-assed it and basically were dipping the bags in the wash solution instead of allowing the 30 second dwell time.  Auditor recorded that as a critical failure because we weren't following our HACCP.  Boss was on site for that audit and was upset with the plant, but also upset the auditor recorded it as a critical.  Yes, it was a breakdown of our HACCP, but SQF's definition of critical includes "...judged likely to cause a significant public health risk and/or product contamination".  Auditor couldn't articulate how a washed bag of baby carrots could likely cause a significant public health risk, and we even agreed it deserved a major, but insisted she record it that way.  We appealed and SQF agreed it was not a critical.

[Lynx42]

We had a customer auditor tell us we should remove the fridges and microwaves from our breakrooms due to risk of glass breakage.  We are a storage facility and most things are pallet in pallet out, some are case in case out.  We have no exposed foods and rarely touch primary packaging.  Same customer who came in to take some samples and brought in glass jars to put the samples in.

 

We also had an auditor tell us if he audits us again we need to make sure to have biological hazards listed on our HACCP.  The code says "can reasonably be expected to occur at each step in the process."  It's all fully packaged by our customers and most things do not have ingredients listed on the outer packaging, so we would have no way of knowing what biological hazards could even possibly be a concern.  Off a truck, into storage, onto a truck, all ambient.  What possible biologicals hazards would reasonably occur other than if damaged which is an automatic hold for disposal? 

[GMO]

 

We also had an auditor tell us if he audits us again we need to make sure to have biological hazards listed on our HACCP.  The code says "can reasonably be expected to occur at each step in the process."  It's all fully packaged by our customers and most things do not have ingredients listed on the outer packaging, so we would have no way of knowing what biological hazards could even possibly be a concern.  Off a truck, into storage, onto a truck, all ambient.  What possible biologicals hazards would reasonably occur other than if damaged which is an automatic hold for disposal? 

 

This goes into systems not people for me so I'm always inclined to raise stuff like this as observations if what you're doing is safe.  But two things I'd have raised (probably as observations), one is in HACCP you should prove you consider something, even if it's not there.  Semantics and nitpicking, yes but people raise non cons for not considering radiological hazards nowadays even if they're pretty rare (and no, your x-ray is not a risk and I'm fed up with reading about that).

 

Secondly, not knowing what the ingredients are of what you have on site does worry me.  You can have some ambient products which are a micro risk in certain conditions.  For example, you could have mould growth resulting in mycotoxins.  But what worries me more is allergens.  While fully wrapped in your facility, we all know fork lift drivers sometimes have an off day (or you sometimes get a duff driver) and damage occurs.  If I was auditing your site or storing my materials there, I'd want to know how you store allergen vs. non allergen goods.  And if I saw signs of allergens being stored above non allergens (yes we would be finding out what is in your pallets) I'd be raising a non con, especially if I saw signs of spillage.

 

The glass you mention?  Meh.  I'd list it on a risk assessment somewhere for completion but it's not genuinely a risk.

[GMO]

Taking a step back, honestly I hate that we've all spent our time arguing about door closures or a single ant.  While I sometimes think sites miss the point of something being indicative of a bigger issue, why is this our jobs?  Or how did we decide this was our jobs?  What does it add to food safety to argue over whether a microwave not in production areas is a risk?  

 

We are sat in a room with an auditor, both technical people who could be spending their time more valuably genuinely arguing the toss over a document or a minute risk when in any factory I could identify tens if not hundreds of behaviours in a day which are going to lead to your next food safety incident long before the things the auditors are raising will.

 

I know culture is hard to see but behaviours which are indicative of culture are not.  (Not if you push back on the Technical Manager who has been trained to lead you round without seeing anything.)

 

It's about time audits actually delivered for food safety not just for due diligence.

[Tony-C]

So you're the guy who ruined it for everybody lol jk.

 

 

It wasn't in the original Technical Standard in the 90's (yes I’m getting on a bit!) and I’m not sure I can claim responsibility for this as from memory I reckon the NC was in 2002. Compulsory metal detection requirements were introduced in the BRC Global Standard for Food Safety with the publication of Issue 6 which was released in 2008.

 

I do remember the auditor saying it was a major conformance because he had seen metal detectors at other sites manufacturing similar products! So nothing to do with the BRC standard at the time. 

 

Also, how do you justify buying 20 odd metal detectors when you have never had a metal complaint? and it wasn't like we didn't get any complaints.

 

Kind regards,

 

Tony

Edited by Tony-C, Yesterday, 05:32 AM.

[GMO]

 

 

Also, how do you justify buying 20 odd metal detectors when you have never had a metal complaint? and it wasn't like we didn't get any complaints.

 

 

Wrong question IMO.  The right question would be if there had ever been a nut or bolt which had fallen off or a piece of metal scrape against another.

 

I used to supply the same product globally in one factory and across the UK and rest of Europe in another.  The complaints from different markets from the same production runs were vastly different.  Even when we knew we'd made a noticeable quality issue which we took the decision to leave in market.  We couldn't even put a number on it from some countries because we literally had zero complaints.  Same method to report, yet the delightful(!) British consumer tended to tell us when others did not.

 

As it's such a laggy metric, I would never justify the absence of metal detection on lack of complaints alone.  Your HACCP risk assessment should be considering risk with likelihood and severity not if somebody complains about it.  They're not the same.

[Tony-C]

Your HACCP risk assessment should be considering risk with likelihood and severity not if somebody complains about it.  They're not the same.

 

Nice one GMO 

 

For your next trick one feels you are going to teach your grandmother to suck eggs  

 

Apologies if I wasn’t clear, in this case there weren’t any NC's related to the HACCP System or lack of control of potential metal foreign bodies. Most of the products were filtered prior to filling and the issue had never been raised previously. 

 

As per my original post there were a fair number of complaints to review over a significant period and so the complaint data was very relevant.

 

From previous SQF Food Safety Code 8.1 Guidance:

 

‘Customer complaints provide an important measure of how well the SQF System is performing. By accurately recording customer complaint types, a supplier can objectively measure changes in their management system and show improvements in a process. Customer complaints may also show trends that have not been identified during processing and normal process control checks.’

 

‘Customer complaints may be the first record that an auditor asks to review when beginning the site audit. Customer complaints can provide an auditor insight into the performance of the supplier’s SQF System and any trend areas that may require greater focus.’

 

Kind regards,

 

Tony